SEC Comment Letter for SB PARTNERS (CIK 0000087047) — Aug 29, 2005
SB PARTNERS (CIK 0000087047)
Date: Aug. 29, 2005 · CIK: 0000087047 · Accession: 0000000000-05-044734
AI Filing Summary & Sentiment
Referenced dates: August 12, 2005
Letter
August 29, 2005 Mail Stop 4561 Via U.S. Mail and Fax (212) 603-4981 Mr. George N. Tietjen III Chief Financial Officer and Treasurer SB Partners 1251 Avenue of the Americas New York, NY 10020
RE: SB Partners Form 10-K for the fiscal year ended December 31, 2004 Filed April 13, 2005 Form 10-Q for the quarterly period ended March 31, 2004 File No. 0-08952
Dear Mr. Tietjen:
We have reviewed your response letter dated August 12, 2005 and have the following additional comment. In our comment, we ask you to provide us with information so we may better understand your disclosure. After reviewing this information, we may raise additional comments.
Please understand that the purpose of our review process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Note 5 Investment in Joint Venture, page 36 1. Your response to prior comment 2 asserts that the criterion of paragraph 5c(ii) of FIN 46(R) is not met because you own only 75% of the joint venture. However, the term "substantially all of the entities activities" does not relate to ownership percentage. Please provide us with a detailed analysis of the activities of the joint venture and explain to us how each activity either is or is not on your behalf. Also, tell us whether your interest in the partnership is as a limited partner or as a general partner.
Please respond to the comments included in this letter within ten business days. If you have any questions, you may contact William Demarest at (202) 551-3432 or me at (202) 551-3486.
Sincerely,
Daniel L. Gordon
Branch Chief
Show Raw Text
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August 29, 2005
Mail Stop 4561
Via U.S. Mail and Fax (212) 603-4981
Mr. George N. Tietjen III
Chief Financial Officer and Treasurer
SB Partners
1251 Avenue of the Americas
New York, NY 10020
RE: SB Partners
Form 10-K for the fiscal year ended December 31, 2004
Filed April 13, 2005
Form 10-Q for the quarterly period ended March 31, 2004
File No. 0-08952
Dear Mr. Tietjen:
We have reviewed your response letter dated August 12, 2005
and
have the following additional comment. In our comment, we ask you
to
provide us with information so we may better understand your
disclosure. After reviewing this information, we may raise
additional comments.
Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects. We welcome
any questions you may have about our comment or on any other
aspect
of our review. Feel free to call us at the telephone numbers
listed
at the end of this letter.
Note 5 Investment in Joint Venture, page 36
1. Your response to prior comment 2 asserts that the criterion of
paragraph 5c(ii) of FIN 46(R) is not met because you own only 75%
of
the joint venture. However, the term "substantially all of the
entities activities" does not relate to ownership percentage.
Please
provide us with a detailed analysis of the activities of the joint
venture and explain to us how each activity either is or is not on
your behalf. Also, tell us whether your interest in the
partnership
is as a limited partner or as a general partner.
Please respond to the comments included in this letter
within
ten business days. If you have any questions, you may contact
William Demarest at (202) 551-3432 or me at (202) 551-3486.
Sincerely,
Daniel L. Gordon
Branch Chief
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Mr. George N. Tietjen III
SB Partners
August 29, 2005
Page 1
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